China Proposes Third Batch of Priority Controlled Chemicals Targeting PFAS and High-Risk Substances

This regulatory move aligns with China’s New Pollutants Control Action Plan and is expected to impact manufacturers, importers, and downstream users across multiple sectors, including petrochemicals, textiles, pharmaceuticals, plastics, coatings, and leather goods.

PFAS in the Crosshairs

A major feature of the draft is the inclusion of per- and polyfluoroalkyl substances (PFASs), known for their persistence, bioaccumulation, and resistance to degradation. PFASs are widely used in firefighting foams, stain-resistant textiles, non-stick coatings, and semiconductor manufacturing.

The draft list classifies PFASs under entry PC064, covering 29 individual substances such as perfluorobutanoic acid (PFBA), PFHxS-related compounds, and PFCAs with long-chain structures. Their inclusion follows increasing global scrutiny of PFAS due to their links to endocrine disruption, cancer, and environmental persistence.

High-Risk Phthalates and Industrial Solvents

The list also names high-use plasticisers such as di(2-ethylhexyl) phthalate (DEHP), dibutyl phthalate (DBP), and benzyl butyl phthalate (BBP), all of which are flagged for reproductive toxicity and endocrine disruption. Industrial solvents like 1,2-dichloroethane and 1,4-dichlorobenzene are also included, given their carcinogenicity and aquatic toxicity.

In total, the draft covers chemicals with carcinogenicity, mutagenicity, reproductive toxicity, endocrine-disrupting potential, or persistent bioaccumulative properties. The MEE used environmental monitoring data, exposure modelling, and toxicological studies to determine the list.

Regulatory Implications for Industry

Inclusion on the list triggers several regulatory obligations:

• Environmental Impact Assessments (EIA) for new projects must disclose quantities, uses, and transformation pathways of listed substances.
• Pollution Discharge Permits must detail substance composition in raw materials, based on design or actual values.
• Soil and Groundwater Protection measures are required for facilities handling listed substances, including corrosion prevention and leak detection systems.

Facilities must also prepare dismantling and pollution prevention plans prior to decommissioning operations involving listed substances.

Call to Action

Stakeholders across the chemicals value chain should review the draft list and assess potential compliance impacts. Comments must be submitted by 2 December to MEE via the provided contact details.